Right to counsel
While a state may have many statutes, court decisions, or court rules governing appointment of counsel for a particular subject area, a "Key Development" is a statute/decision/rule that prevails over the others (example: a state high court decision finding a categorical right to counsel in guardianships cases takes precedence over a statute saying appointment in guardianship cases is discretionary).
Litigation, Civil Commitment - Subject of Petition
In In re Fisher, 39 Ohio St. 2d 71, 74, 313 N.E.2d 851, 854 (Ohio 1974), the Ohio Supreme Court declared a federal constitutional right to counsel in civil commitment proceedings. The court described in detail "the scope and gravity of the constitutional rights involved and the serious deprivations of liberty resulting from involuntary civil commitment." These included the procedural infirmities associated with such proceedings (such as the unavailability of appellate review) and the various statutory restrictions placed on the mentally disabled. As the court explained, appointment of counsel was necessary in commitment proceedings because "[t]here is no mandatory requirement that anyone protect the rights of the individual."
If "yes", the established right to counsel or discretionary appointment of counsel is limited in some way, including any of: the only authority is a lower/intermediate court decision or a city council, not a high court or state legislature; there has been a subsequent case that has cast doubt; a statute is ambiguous; or the right or discretionary appointment is not for all types of individuals or proceedings within that category.
Appointment of Counsel: categorical Qualified: no